The OWMA has heard concerns from a number of members about the timeline for approvals from the Ministry of Environment & Climate Change (MOECC). From our meeting with the MOECC last week, it is our understanding that while the time to process waste approvals are coming down, the median remains high at 307 days. The MOECC has committed to working with the OWMA on this issue - something the Minister was quite vocal about at our last Annual General Meeting.
As a result, the OWMA has created a committee to work with the government to find solutions including finding ways to better utilize and increase opportunities currently available through the approvals process like flagging projects as priority, streamlining the review process (to identify problems earlier), utilizing limited operational flexibility mechanisms (allow for some modifications to specifically defined aspects of the facilitys operations without having to obtain an amendment), and multi-media approvals (a single approval that combines all aspects of the site for air/noise, wastewater, and/or waste). The committee will also be working with the government to look at new approaches to waste approvals as part of the modernization discussion and keeping the members better informed on their options.
OWMA has a seat at the MOECC Approvals Modernization Roundtable and has supported changes in terms of the EASR system for MOECC ECAs for waste vehicles (systems certificates) and other initiatives to improve the overall approval system. The MOECC will be conducting a technical review of the risks associated with municipal waste recycling facilities (MRFs), both private & public, to determine if these facility approvals are a candidate for a self-registration approval and what regulatory requirements would ensure adequate environmental protection. The MOECC will utilize the technical assessment to inform project scope and the drafting of a technical discussion paper. OWMA will focus membership interests and knowledge into the discussions at the Roundtable regarding MRFs over the coming year.
The MOECC through the approvals modernization process is also developing a pilot program to remove the barriers to innovative technologies. This includes new technologies in the waste sector (to align with Bill 151 and climate change objectives). The development of a more permanent approach could include innovative technology verification by other comparable jurisdictions as an accepted starting point for MOECC approvals.
Hazardous Waste Import/Export Permits
OWMA staff met with Environment Canada (EC) staff last week to discuss concerns with the speed at which Environment Canada was providing approvals for import permits. EC staff explained the issue with the vast majority of applications are not completed correctly (e.g. missing fields, company name not complete, differences between US and Canadian forms). They did say that the use of the new on-line system has improved these numbers for those using it (e.g. it has prescriptions to ensure forms are complete) but still the majority of companies are not using this system (despite broad information sessions held by EC).
Based on feedback from members, we identified three areas of concern:
Wording of contracts - EC explained that the regulation is very clear and prescriptive in the wording of contracts and has not changed so this should not be an issue. They did say they are paying more attention to this area given some of the streamlining that occurred as a result of the online forms.
Classification / waste codes - EC were surprised that there was any issue here as they have not heard anything about this. OWMA committed to provide specific examples.
Piecemeal Corrections - EC explained that this may occur due to conversations with the US and various provinces as issues identified. They did also explain that they have moved away from specific case officers due to the move to the online tool and some concerns they were having with consistency in treatment, turnover or absences.
The Hazardous Waste committee will be providing more in-depth comments to the EC and working to find ways to reduce current timelines.
Transportation of Dangerous Goods (TDG) Meeting
OWMA representatives met with five Transport Canada (TC) TDG representatives in Ottawa on May 18th, 2016. The meeting was very productive and discussions were very cordial. Three subject areas were reviewed - a revised standard for the transport of aerosol containers (CGSB-43.123 - Aerosol Containers and Gas Cartridges for Transport of Dangerous Goods / 55.130), Equivalency Certificates and a potential revision to the CGSB standard for large packaging. As a result of the meeting, significant changes to the aerosol standard requested by the OWMA were positively received. Changes will be made as a result of our meeting and TC is open to additional requests for change as part of the review process. We will be drafting our submission and will be circulating it next week to the Hazardous Waste Committee. Equivalency Certificates were also discussed and it was confirmed that permits will be revoked from a packaging perspective but may still be required for other issues such as labelling. We also discussed large containers and a proposal for continuing the use of gaylords and wrangler type containers. We were asked to send our thoughts in writing but it appeared there was some agreement from TC to move in this direction.
TC indicated an interest in engaging with the association in the future on these issues as it represented a broader perspective on behalf of service providers.
Disposal of Street Sweeping Material
The MOECC has posted a notice for a proposed Directors Order under Sections 18, 43 and 196 of the Environmental Protection Act (EPA) regarding the deposit of waste street sweepings at numerous sites throughout Ontario. While this order focuses on one municipality, it could have much broader implications around the definition of waste and could impact others. The draft order can be found here and the Provincial Officer's Report can be found here.
The OWMA is reaching out to the Regional Public Works Commissioners of Ontario (RPWCO) to discuss the issue and if any next steps are required. We would appreciate any feedback on this issue - email@example.com.
MOECC Ministers Award for Environmental Excellence
The Ministry of Environment & Climate Change has released applications for this years Ministers Award for Environmental Excellence, which will focus on outstanding efforts to recover and reuse resources that are contained in waste.
Examples could include the recovery of nutrients, energy, and water from greenhouse operations, water and wastewater treatment systems, and waste systems. Information on the award can be found at https://www.ontario.ca/page/ministers-award-environmental-excellence. We encourage you to submit an application.
Waste-Free Ontario Act
The Waste-Free Ontario Act remains at 3rd Reading debate and we expect it to pass before the end of the month. Information on the amendments at committee and debate so far at 3rd reading can be found here. Also a reminder that a complimentary webinar of the Act will be held at noon on June 8th. Please register on the OWMA website www.owma.org.